Michigan Department of Education Child and Adult Care Food Program (CACFP)
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Michigan Department of Education Child and Adult Care Food Program (CACFP)
Michigan Department of Education Child and Adult Care Food Program (CACFP) Family Day Care Home Sponsor Administrative Review Sponsor: ❒ Announced Date Agreement # ❒ Unannounced ❒ Overpayment disregard used Number of homes approved as of 9/30/__ Number of homes approved as of _____________________ (Date of review) Number reviewed A. General Information Recordkeeping 1. All records are available to support claims for 3 years plus the current year. [7 CFR 226.10(d)] ❒ Y ❒ N 2. The sponsor distributed information about the benefits of the CACFP to all parents. [7CFR 226.16(b)(5)] ❒ Y ❒ N 3. The application and all supporting documentation submitted to MDE is on file. [7 CFR 226.15(e)] ❒ Y ❒ N 4. Sponsor ensures that the WIC poster is posted at sites or WIC materials are given to parents/guardians. [7 CFR 226.6(r)] ❒ N/A ❒ Y ❒ N 5. Attach a copy of the institution page. Verify information and note changes below. 6. The sponsor has written recruitment and outreach practices as part of their management plan. ❒Y ❒ N 7. The written recruitment and outreach practices are being implemented. ❒Y ❒ N Comments B. Board of Directors and Oversight – if applicable 1. Number of board members. 2. Board members related to each other or any other staff. ❒ N/A ❒ Y ❒ N If yes, list names, positions, and relationships: 3. Conflict of interest policy includes conflict disclosure and procurement. Page 1 of 13 ❒ N/A ❒ Y ❒ N 4. List dates of the three most recent board meetings and note whether CACFP oversight is documented in the minutes. Meeting Date CACFP Oversight Documented □ □ □ Yes Yes □ □ □ No No 5. Yes No Schedule of board meetings reviewed. ❒ N/A ❒ Y ❒ N 6. Board has oversight of administrative and financial decisions. ❒ N/A ❒ Y ❒ N 7. Board has authority to hire and terminate executive director. ❒ N/A ❒ Y ❒ N C. 1. Training The sponsor conducted training for all key staff prior to CACFP operations on: (new facilities only) [7 CFR 226.16(d)(2)] ❒ meal patterns ❒ meal counts ❒ N/A ❒ Y ❒ N ❒ claims submission and claim review procedures ❒ recordkeeping requirements 2. ❒ the sponsor’s reimbursement system The sponsor conducted annual CACFP training for all key staff on: [7 CFR 226.16(d)(3)] ❒ meal patterns ❒ meal counts ❒ Y ❒ N ❒ claims submission and claim review procedures ❒ recordkeeping requirements 3. ❒ the sponsor’s reimbursement system The sponsor trained staff with monitoring responsibilities annually on: [7 CFR 226.15(e)(14)] ❒ meal patterns ❒ meal counts ❒ claims submission and claim review procedures ❒ recordkeeping requirements 4. ❒ the sponsor’s reimbursement system Training documentation includes: [7 CFR 226.15(e)(12)] ❒ date(s) ❒ location(s) ❒ topic(s) ❒ names of participant(s) Comments D. Provider Training 1. The sponsor conducted training for each provider prior to CACFP operations on: [7 CFR 226.16(d)(2)] ❒ meal patterns ❒ meal counts ❒ claims submission and claim review procedures ❒ recordkeeping requirements ❒ the sponsor’s reimbursement system ❒ civil rights requirements Page 2 of 13 ❒ Y ❒ N 2. The sponsor conducted annual CACFP training for each provider on: [7 CFR 226.16(d)(3)] ❒ meal patterns ❒ meal counts ❒ claims submission and claim review procedures ❒ recordkeeping requirements ❒ the sponsor’s reimbursement system ❒ civil rights requirements 3. Training documentation includes: [7 CFR 226.15(e)(12)] ❒ date(s) ❒ location(s) ❒ topic(s) ❒ names of participant(s) Comments E. Procurement [7 CFR 226.21, 7 CFR 226.22] 1. Annual vendor selection documentation is available to support the small purchase method for all purchases less than $150,000. ❒ N/A ❒ Y ❒ N 2. A competitive bid process is used for purchases over $150,000. If yes, documentation is available to support the competitive bid procedure. ❒ N/A ❒ Y ❒ N ❒ Y ❒ N If applicable, contracts were submitted to MDE. ❒ N/A ❒ Y ❒ N For contracted services, the terms of the contract were followed. ❒ N/A ❒ Y ❒ N Written Code of Conduct and performance available for staff engaged in award and administration of contracts. ❒ N/A ❒ Y ❒ N ❒ N/A ❒ Y ❒ N ❒ Y ❒ N 3. 4. Comments F. 1. Financial Management Sponsor obtained audit, if required. If applicable, the sponsor implemented corrective action(s) to any findings. 2. The sponsor has written procedures for financial management. ❒ Y ❒ N 3. The written procedures for financial management are being adhered to. ❒ Y ❒ N 4. Payments to providers are made within 5 working days of receipt from MDE. [7 CFR 226.16(h)] ❒ Y ❒ N 5. Administrative earnings and meal reimbursement money are tracked separately in sponsors’ financial system. 6. No checks were outstanding for more than two months. If no, list on worksheet. Page 3 of 13 ❒ Y ❒ N ❒ Y ❒ N 7. Number of insufficient funds or late fee charges during the four month period beginning with the month before the review month. 8. Describe any check clearing irregularities: Comments: G. Administrative Costs and Claim [7 CFR 226.15(e), 7 CFR 226.14(a)] Verify the accuracy of figures reported and supporting documentation for test month selected Item Amount Claimed (✓ ) if okay If not checked, note problem Salaries Benefits Travel Occupancy Contracted Services Supplies Training Equipment Other Total 1. 2. MDE monthly approved budget. Administrative costs claimed for 3. Documentation was available to support all costs reported on the claim. List discrepancies on worksheet. ❒ Y ❒ N 4. A copy of the claim is on file. ❒ Y ❒ N 5. Documentation is available to verify receipt of CACFP reimbursement payments received from MDE. ❒ Y ❒ N 6. List any questionable payments on worksheet. 7. YTD administrative costs are within approved YTD budget. ❒ Y ❒ N 8. YTD administrative costs are less than 30% of the total of administrative payments and meal payments to providers. ❒ Y ❒ N 9. If it appears that costs exceed reimbursement over an extended period, identify the other sources of income available to the sponsor to meet financial liabilities incurred in excess of reimbursement. 10. The sponsor only receives CACFP funding. If sponsor receives public or private funding in support of its CACFP operation, explain below. (test month) 11. The sponsor’s non-profit food service report is within its 3 month operating balance. [FY 2005 Operational Memo #34] Page 4 of 13 $ $ ❒ Y ❒ N ❒ Y ❒ N 12. The sponsor has a board-approved written employee compensation policy. ❒Y ❒ N 13. The sponsor has a current cost allocation plan. ❒ N/A ❒ Y ❒ N 14. The sponsor is following their cost allocation plan. ❒ N/A ❒ Y ❒ N 15. If this review is a follow-up review and over-claims were assessed at the previous review, what funds did the sponsor use to cover the amount deducted for the over-claim? ______________________________________________________________________ ______________________________________________________________________ Comments: H. 1. 2. Tiering/Income Eligibility/Enrollment The sponsor has implemented the tiering system described in the Management Plan for identifying and determining Tier 1 and Tier 2 homes. A system is in place to ensure that Tier 1 determinations are made: Each year for income eligibility forms ❒ Y ❒ N ❒ Y ❒ N Every five years for school data ❒ Y ❒ N When new census data is issued ❒ Y ❒ N 3. The sponsor has informed Tier 2 providers of the option of identifying income eligibility children in their care. ❒ Y ❒ N 4. The sponsor makes income eligibility forms available to households of children enrolled in Tier 2 homes at the provider’s request. ❒ Y ❒ N 5. Completed income eligibility forms are sent directly from the households to the sponsor or a consent is signed by the household if the provider sends the IES to the sponsor on the household’s behalf. ❒ Y ❒ N 6. The sponsor maintains the confidentiality of income eligibility information. ❒ Y ❒ N 7. Number of providers: Tier 1 (Area Eligible) _________ Tier 1 (Income) _________ Tier 1 (Census) _________ Tier 2 (Mixed) _________ Tier 2 _________ TOTAL _________ Total approved Provider Income Eligibility Statements Total approved Household Income Eligibility Statements Total approved Income Eligibility Statements 8. 9. Percentage of Provider Income Eligibility Statements to review Number reviewed by MDE Percentage of Household Income Eligibility Statements to review Number reviewed by MDE Page 5 of 13 ___ ___ % % 10. Documentation is on file to support Tier 1 reimbursements for the following categories: Tier 1 – area eligible based on school data ❒ Y ❒ N Tier 1 – area eligible based on census data ❒ Y ❒ N Tier 1 – eligible based on income, including verification ❒ Y ❒ N Tier 2 - provider with income eligible day care children ❒ Y ❒ N Comments: I. Enrollment [7 CFR 226.15(e)(2) and 226.17(b)(8)] (Not applicable for at-risk programs and emergency shelters) 1. Current enrollment documentation is on file for each participant claimed. If no, see worksheet. 2. Enrollment forms are updated annually. 3. Enrollment forms contain: ❒ N/A ❒ Y ❒ N ❒ N/A ❒ Y ❒ N ❒ Participant’s name ❒ Dated participant’s, parent, or legal guardian signature ❒ Normal days and hours in care ❒ Meals normally received while in care Comments _________________________________________________ ___________ ___________________________________________________________ ____________ ________________________________________________________________________ J. Sponsor Monitoring [7 CFR 226.16(d)(4)(i-viii)] Previous fiscal year: Number of active homes on September 30 _______ Number of home reviews _______ Current fiscal year: Number of active homes as of date of review Number of home reviews _______ _______ Answer the following questions from: A list of reviews for the current and previous fiscal year by facility listing the review date, unannounced or announced and meal observed; Review forms conducted for current and previous fiscal years; and Review criteria in CACFP FY2005 Memo #41. 1. The sponsor reviewed each site the required number of times per year. Sites operating 12 months – 3 reviews Sites operating 9 months or less – 2 reviews Sites operating 4 months or less – 1 review ❒ Y ❒ N 2. Each facility received at least two unannounced reviews last year. ❒ Y ❒ N Page 6 of 13 3. At least one unannounced review included a meal observation. 4. For new facilities: At least one review was made during the facility’s first 4 weeks of CACFP operation. 5. There were no more than 6 months between reviews. 6. ❒ Y ❒ N ❒ N/A ❒ Y ❒ N ❒ Y ❒ N Monitoring reviews were documented. ❒ N/A ❒ Y ❒ N 7. The monitoring forms were complete. ❒ N/A ❒ Y ❒ N 8. Facility reviews assess compliance with: ❒ meal patterns ❒ menu/meal records ❒ enrollment forms 9. ❒ licensing or approval ❒ attendance at training At facility reviews, the sponsor assesses whether each facility has corrected problems noted on previous reviews. ❒ N/A ❒ Y ❒ N 10. A reconciliation of the facility’s meal counts with enrollment and attendance records for a 5 day period is conducted at each review. ❒ Y ❒ N 11. Facility review averaging is used. If yes: ❒ Y ❒ N An average of 3 reviews per facility are conducted; ❒ Y ❒ N ❒ Y ❒ N ❒ Y ❒ N ❒ N/A ❒ Y ❒ N 14. Did the sponsor perform an adequate number of reviews of each meal type claimed by its facilities? ❒ Y ❒ N 15. Does the sponsor have a review system that ensures variability in the timing of monitoring visits? ❒ Y ❒ N 16. Is the sponsor in compliance with the monitor staffing ratios in 226.16(b)(1)? ❒ Y ❒ N If a facility receives two reviews in one year, the next review is conducted within nine months. 12. If a facility was seriously deficient, the next review was unannounced. 13. Does the sponsor have a review system which ensures the monitoring of all meal types claimed by the facilities? Number of facilities _____ Number of FTE monitors _____ 17. Number of homes reviewed by MDE with no findings. _______________ 18. Number of homes reviewed by MDE with findings but no serious deficiencies. 19. Number of homes reviewed by MDE with serious deficiencies. 20. Were the findings from the reviews corrected? Page 7 of 13 ❒ Y ❒ N Comments K. Provider Serious Deficiencies 1. The sponsor complied with the serious deficiency, suspension, and termination requirements in 226.16(l). ❒ Y ❒ N 2. The sponsor initiates some type of provider performance standard and moves on a non-compliance issue into the SD process when there is a repeat finding or the finding is flagrantly out-of-compliance. ❒ Y ❒ N 3. The sponsor enforces the 30-day deadline for providers’ completion of corrective action in response to a notice of SD. 4. The sponsor promptly moves to issue a Notice of Proposed Termination and Disqualification (NPTD) when corrective action is not complete and permanent. ❒ Y ❒ N ❒ Y ❒ N 5. The sponsor ensures that each serious deficiency action initiated is either corrected, or the provider is terminated for cause and disqualified. ❒ Y ❒ N 6. The sponsor makes appropriate decisions regarding the acceptance of particular corrective actions to resolve the providers’ SD, especially in cases involving the submission of false or fraudulent claims. ❒ Y ❒ N 7. Number of household contacts made. #_____________ 8. The sponsor conducted household contacts in accordance with the MDE household contact procedure. ❒ Y ❒ N Comments L. Provider Appeals 1. Number of provider appeals requested in FY ____ #_____________ 2. Number of provider appeals held in FY ____ #_____________ 3. Sponsor is utilizing MDE Appeal Procedures ❒ N/A ❒ Y ❒ N ❒ N/A ❒ Y ❒ N 4. If no, describe the process the sponsors uses. _____________________________________________________ _____________________________________________________ 5. If applicable, the sponsor’s appeal process was followed. Page 8 of 13 6. Name(s) of hearing official(s) ______________________________________________ ______________________________________________________________________ 7. Describe the official’s qualifications __________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 8. Describe the official’s relationship with the SO and/or staff and any less than arms length transactions _____________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ 9. Describe how hearing official(s) are trained at least annually on CACFP regulations and guidance _______________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ 10. Review 3 appeals files. Summarize findings: _________________________________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ M. Provider File Maintenance and Claim Processing Number of files reviewed Provider File Maintenance Summary Items Reviewed Number Provider Name(s) Missing Application Missing Sponsor/Provider Agreement Missing IES, if applicable Incorrectly classified IES Missing Monitoring Review Forms Missing Documentation to Support Tier Status Missing License/Registration Number Items Reviewed Number Provider Name(s) Missing Name, Address, Phone Number Missing Signature of Provider Missing Enrollment Form signed by parents/each child claimed Missing Meal Attendance Recorded by date and meal type by child Missing Verification for holiday/weekend meals Missing Daily Infant Menus to support meals claimed Missing Daily Menus to Support Meals claimed Number of Provider reviews/monitoring visits not conducted within required timeframe Page 9 of 13 Number of reviews monitored for correct variety of milk Number of reviews monitored for availability of water Number of Incorrect Tier Determinations Number of Meal Times not approved by Sponsor Number of Meal Times not the same as approved by Sponsor Number of Providers who did not record meal attendance by name Number of Providers with incomplete enrollment forms Number of Providers who did not update enrollment forms annually Number of Providers claiming children not within age limits Number of Providers claiming own children when other day care children not present and claimed Number of Providers claiming more than allowable meals/snacks per child per day Number of Providers not within DHS capacity Number of Providers claiming more than 28 days in February, or 30 days in Sept. April, June and Nov Number of Providers with few or no absences Number of Providers with total number of meals/snacks counted incorrectly Number of Providers submitting menu different than sponsor monitor observed Number of Providers submitting menu different that MDE monitor observed Items Reviewed Number of Providers whose menus did not meet meal pattern requirements Number of Providers Claim Value did not match check register Number of Providers Reimbursed for meals/snacks not approved by sponsor/MDE Number of Providers whose payments were not made within 5 working days of receipt of USDA funds Number of Providers who should have been declared SD but were not Number of Providers who should have had Household contacts conducted but did not Number of Checks that did not clear the bank Number Page 10 of 13 Provider Name(s) 1. Describe how the sponsor notifies the provider of problems identified during worksheet processing such as non-reimbursable meals, claiming more than the allowable number of meals per child per day, etc. 2. The sponsor implements the menu and worksheet processing system approved in the Management Plan. ❒ Y ❒ N 3. The sponsor’s edit system used during worksheet processing insures accurate provider reimbursement. ❒ Y ❒ N 4. The sponsor uses the following systems to process claims: Check all that apply ❒ Manual ❒ Accutrack ❒ Web Based ❒ Minute Menu ❒ Y ❒ N ❒ Y ❒ N 5. ❒ Other-describe: _________________________________ The edit system(s) detect: [7 CFR 226.10(c)(1)(2)] Unapproved meals Maximum number of meals by multiplying enrollment by number of approved meals by number of operating days Comments N. Civil Rights [FNS Instruction 113-1, 7 CFR 226.6(m)(1), 7 CFR 226.6(b)(4)(iv)] 1. Ethnicity and race data is collected, complied and compared annually for program participants. ❒ Y ❒ N 2. All potentially eligible persons and households have an equal opportunity to participate in the CACFP. ❒ Y ❒ N 3. The USDA “And Justice for All” poster is displayed in a conspicuous location. ❒ Y ❒ N 4. The USDA nondiscrimination statement is on all materials such as applications, pamphlets, forms or other program materials distributed to the public and on web sites. ❒ Y ❒ N 5. All CACFP materials distributed to the public and on websites reflect diversity based on race, color, national origin, age, sex, and disability. ❒ Y ❒ N 6. The institution has a civil rights complaint procedure. ❒ Y ❒ N 7. Civil rights complaints are being handled appropriately. ❒ N/A ❒ Y ❒ N 8. Staff received civil rights training in the ❒ Collection and use of data ❒ Effective public notification systems ❒ Complaint procedures ❒ Compliance review techniques ❒ Resolution of noncompliance ❒ Customer service following areas: ❒ Requirements for reasonable accommodations of persons with disabilities ❒ Requirements for language assistance ❒ Conflict resolution Page 11 of 13 9. CACFP information is made available to potentially eligible persons, CACFP participants, and community organizations to reach potentially eligible populations. ❒ Y ❒ N Comments _ _ O. Previous Reviews & Findings 1. There were findings from previous review. If yes, list ❒ N/A ❒ Y ❒ N 2. Findings from previous reviews were corrected. ❒ N/A ❒ Y ❒ N Comments _ P. Home Review Issues Q. Current Issues/Best Practices Describe innovations, new projects, current concerns or other issues specific to the sponsor. Page 12 of 13 Summary of Review Findings and Corrective Action Requirements No findings No further corrective action required Submit all corrective actions to the address below by Letter to follow Overpayment disregard used Claim amendments required Application amendments required Findings must be corrected permanently. Repeated non-compliance will jeopardize future Child and Adult Care Food Program (CACFP) participation. Submit claim amendments, if required, within 30 days of the date of this notice; otherwise, the amendments will be processed by the Michigan Department of Education (MDE), deducting the maximum possible. MDE provided a copy of: (check all that apply) Review Form Summary of Findings Institution Signature: Date: MDE Signature: Date: Appeal Procedures If you wish to appeal these findings and/or corrective actions, you must adhere to the CACFP Appeal Procedures. Send corrective action to: Michigan Department of Education Office of School Support Services Child & Adult Care Food Program P.O. Box 30008 Lansing, MI 48909 Fax: (517) 373-4022 Phone: (517) 373-7391 S:CACFPStaff/Review Forms/Homes/FDCH Sponsor Administrative Review Page 13 of 13 Rev. 10/2015